Managing Packaging Compliance Across Food & Beverage Manufacturing Operations

Food and beverage manufacturers are managing packaging requirements related to Extended Producer Responsibility (EPR), per- and polyfluoroalkyl substances (PFAS), recycled content, and reporting. Knowing what materials are used, where products are sold, and what packaging data is available can help manufacturers maintain compliance, manage reporting obligations, and prepare for changing requirements.

Tim Olson Sr. Environmental & Sustainability Regulatory Advisor APTIM | Environmental Compliance & Sustainability Email

Food and beverage manufacturers use packaging throughout production and distribution, including containers, films, cartons, labels, closures, shipping materials, and food service items. Depending on the product and where it is sold, these materials may be subject to different state requirements.

Managing EPR, PFAS, recycled content, and packaging reporting requirements begins with accurate packaging information and coordination among compliance, procurement, operations, sustainability, legal, and supply chain teams.

Packaging Requirements Affecting Food & Beverage Manufacturers

Packaging regulations vary by state, material, and product type. For manufacturers selling products across the country, the same package may be subject to different reporting, fee, recycled content, or documentation requirements.

California's Plastic Pollution Prevention and Packaging Producer Responsibility Act (SB 54) establishes an EPR program for packaging and single-use plastic food serviceware. California's permanent SB 54 regulations took effect May 1, 2026. The law includes requirements related to source reduction, recyclability or compostability, and recycling rates for covered materials. Manufacturers should also determine whether exclusions or exemptions apply to specific food and agricultural packaging.

Oregon's Plastic Pollution and Recycling Modernization Act provides another example. Producers of covered packaging, paper products, and food serviceware must register with a producer responsibility organization, report covered products supplied to Oregon, and pay applicable fees. Oregon's program launched in July 2025, and specific producer and product exemptions may apply.

In August 2026, a federal court upheld the law against constitutional challenges, allowing Oregon to continue implementation while related EPR litigation proceeds in other states.

Food and beverage manufacturers should also account for recycled content requirements that apply to certain packaging. In California, plastic beverage containers subject to the state's beverage container program must contain an average of at least 25% postconsumer recycled plastic from 2025 through 2029. The requirement increases to 50% beginning in 2030, subject to provisions of the law.

PFAS is another consideration for food packaging. In January 2025, the US Food and Drug Administration (FDA) determined that 35 food contact notifications for PFAS-containing grease-proofing substances used on paper and paperboard food packaging were no longer effective after manufacturers and suppliers abandoned those uses. The FDA had previously announced that these PFAS-containing grease-proofing agents were no longer being sold for food contact use in the US market.

These requirements make accurate packaging information essential for compliance. Companies need to know what materials they use, how packaging is classified, where packaged products are sold, and what documentation is available.

Packaging Data & EPR Reporting

Accurate packaging data is central to EPR reporting and other packaging requirements. For a manufacturer with hundreds or thousands of stock keeping units (SKUs), collecting that information can require coordination across several systems and departments.

Seven states now have packaging EPR laws: California, Colorado, Maine, Maryland, Minnesota, Oregon, and Washington. Implementation schedules differ, but reporting is no longer merely a future concern. Relevant packaging information may include:

• Material type & composition
• Packaging weight
• Recycled content
• Product & packaging format
• Sales or distribution by state
• Supplier information
• Recyclability or compostability
• PFAS or other chemical information

This information may be stored across procurement systems, bills of materials, supplier specifications, production records, sustainability databases, and spreadsheets.

Data gaps can complicate compliance reporting. Missing packaging weights, inconsistent material classifications, or outdated supplier information can affect EPR reporting, fee calculations, recycled content documentation, and assessments of material restrictions.

A consistent packaging inventory gives manufacturers a reliable starting point for compliance reporting and future packaging decisions.

Supplier Coordination & Packaging Compliance

Manufacturers often depend on suppliers for information about packaging composition, coatings, recycled content, chemical content, and other technical specifications.

Supplier data requests should clearly identify what information is needed and how it should be documented. Depending on the requirement, manufacturers may need specifications, certifications, declarations, or other supporting records.

PFAS is one example. Manufacturers need enough information about supplied materials to evaluate applicable requirements and document packaging specifications.

The same applies to EPR and recycled content reporting. Establishing standard supplier data requirements can help manufacturers collect consistent information and reduce repeated requests as additional state requirements take effect.

Evaluating Packaging Compliance Across Manufacturing Operations

A packaging compliance review can begin with an inventory of packaging materials and the products that use them. Manufacturers can then compare that information with where products are sold and which requirements apply.

Key steps include:

• Inventory packaging types & materials across product lines
• Identify applicable EPR, recycled content & material requirements by state
• Determine which entity is considered the producer under applicable EPR laws
• Establish consistent packaging weights & material classifications
• Identify missing supplier specifications & documentation
• Develop processes for collecting & validating packaging data
• Assign responsibility for reporting & recordkeeping
• Track regulatory deadlines

This review may also identify duplicate materials, inconsistent specifications, or packaging formats that could be standardized. Any changes should account for food safety, product protection, shelf life, production equipment, cost, and distribution requirements.

Managing Packaging Changes & Compliance Risk

Packaging decisions can involve several departments. Procurement evaluates cost and availability. Operations considers production requirements. Marketing focuses on the product and consumer experience. Environmental and sustainability teams evaluate regulatory requirements, material reduction, and recyclability.

A process for reviewing new or modified packaging can help identify compliance requirements before materials are purchased or introduced into production.

Even a small packaging change can affect material classifications, EPR reporting, recycled content requirements, fees, or supplier documentation. Maintaining records of packaging specifications, classifications, and reported quantities can help manufacturers respond when products, suppliers, or requirements change.

Steps Food & Beverage Manufacturers Can Take Now

Manufacturers can take several practical steps to strengthen packaging compliance:

• Develop or update a packaging inventory
• Identify the states where packaged products are sold
• Review applicable EPR, PFAS & recycled content requirements
• Identify missing packaging & supplier data
• Establish consistent material classifications & calculation methods
• Define responsibilities across compliance, procurement, operations & sustainability teams
• Incorporate compliance review into packaging changes & new product development
• Maintain documentation for reporting & compliance decisions

Together, these steps create a more consistent basis for reporting and give manufacturers the information needed to evaluate packaging materials, suppliers, and future changes.

The practical objective is to create an auditable chain of packaging information and compliance documentation. Manufacturers with that foundation can respond to new statutes and changing reporting categories more efficiently.

How APTIM Supports Packaging Compliance

APTIM helps food and beverage manufacturers manage packaging requirements across products, suppliers, facilities, and states.

Our team supports packaging inventories, regulatory applicability reviews, EPR reporting, packaging data management, supplier coordination, recycled content evaluations, PFAS reviews, and regulatory tracking.

APTIM can also help manufacturers identify data gaps, establish reporting processes, and incorporate packaging requirements into existing environmental compliance and waste management programs.

Connect with APTIM's environmental compliance team to evaluate packaging requirements, identify data and documentation gaps, and establish processes for managing EPR, PFAS, recycled content, and reporting obligations.

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Published September 2026

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